Our loan originators are issuing new GFEs based on valid COC however in addition to the fees allowed to change, they are changing block 9 because the initial escrow deposit has changed since the original GFE due to additional insurance and/or tax payments. The change is just to give the borrower a heads up for closing costs - I know that even though it does not figure into the tolerance issues they should not change the escrow fees but does anyone give the borrower another form just to keep them updated on what to expect for closing?

Thanks

Our loan originators are issuing new GFEs based on valid COC such as a rate lock, however in addition to the fees allowed to change on the new GFE, they are also increasing the fees in block 9 because additional taxes and insurance are now required for the initial escrow deposit. They have gotten an opinion from the Bank's QC review company (Synergy) that because the fees are in in an area that is not subject to cure or tolerance levels, that change (which has nothing to do with the COC) is allowed and not considered a documentation error.

Has anyone else heard of this opinion?

Page 1 of the GFE must match page 3 of the final HUD-1. so whether a borrower is escrowing or not would logically require re-disclosure. However, the amount of the escrow balance is not a tolerance issue and should not require redisclosure.

It goes further than should not require redisclosure.
The FAQ clearly states numerous times that you are not allowed to change any numbers that are not directly related to the valid changed circumstance that triggers the redisclosure.
Example from the top of p.18:

Additionally, read my mini rant here which is totally applicable in this circumstance too. LOs have numerous ways to communicate funds needed to close to the borrower. The GFE was never intended to be one of those ways. It is only an estimate of closing costs. Trying to make it more could land you in trouble with your examiners.